Mr. Gerry Cross:

I thank Senator Burke for his question. Obviously, the reforms introduced over the past eight to ten years have been significant and have completely transformed the regulatory and supervisory landscape, given that we saw what happened before.

That has been hard for Irish and other banks and it has placed demands on them. These demands are, nevertheless, very much the right demands.

I agree with Mr. Gilvarry on the current package. The key changes to the leverage ratio and the net stable funding requirement have been very well flagged. They are subject to an ongoing monitoring exercise by the European Banking Authority, involving reporting rather than setting requirements. There is a little bit of a way to go for some banks resident here but, on the whole, compliance will not be unduly challenging.

The package brings in transitional measures for the introduction of IFRS 9. The assessment of what its impact might be remains ongoing and banks are introducing systems for it but we know there will be some impact so the proposals allow four years so that the impact is smooth, which is very sensible. We fully support IFRS 9 as a very important measure but it is very helpful to allow a period of smoothing in order to avoid a cliff effect when it comes into force next year. Some aspects of the proposal will reduce requirements and there will be some alleviation for SMEs and in respect of infrastructure. We do not see a disproportionate impact in this package.